Lease rent for aquaculture land qualifies for GST exemption where the water channel is treated as land used for rearing animals.

Lease rent for a water channel used in fish and crab farming is covered by the exemption for services relating to rearing of all life forms of animals by way of renting or leasing of vacant land under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate). The ruling treated the arrangement as renting of immovable property and accepted that the water channel constituted land for purposes of the entry. Because the land was used for aquaculture, the activity satisfied the condition of rearing animals and remained exempt.

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Issues: Whether lease rent charged for a water channel used for fish farming falls within the exemption for services relating to rearing of all life forms of animals by way of renting or leasing of vacant land under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Analysis: The exemption entry covers services relating to cultivation of plants and rearing of all life forms of animals by way of renting or leasing of vacant land with or without a structure incidental to its use. The land in question was provided on lease, and the arrangement answered the description of renting of immovable property under paragraph 2(zz) of the notification. The water channel was treated as land for the purpose of the entry, and the land was used for fish and crab farming, which satisfied the requirement of rearing of animals.

Conclusion: The lease rent charged for the water channel used for fish farming is covered by the exemption under Sl. No. 54 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

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